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Letter to Assistant Deputy Minister Barbra Walman – April 12, 2013

April 12, 2013

Mrs. Barbra Walman
Assistant Deputy Minister
Pharmaceutical Services
3-2 – 1515 Blanshard Street
Victoria, BC V8W 3C8

Dear Mrs. Walman:

RE: Copy of a survey recently completed with a sample of people treated for AMD in British Columbia

We are writing to follow-up our meeting of September 21 2012 when we outlined we were undertaking a survey of patients affected by AMD who reside in British Columbia. Results of the AMD patient survey (copy attached) demonstrate that a majority of patients in this province are not being made aware of available AMD treatment options or what intravitreal medication they are receiving. Further to this a majority of patients in BC who were interviewed for our survey were neither given a treatment option nor told about the potential for serious adverse events as a result of treatment with off-label Avastin.

As referenced in the BC Ministry of Health’s publication dated October 2012, a document entitled “Best Practice Guideline for Accommodating Behavioral and Psychological Symptoms of Dementia in Residential Care”, BC’s Health Care (Consent) and Care Facility (Admission) Act indicates that BC patients must be provided with full disclosure of available treatment options, and that each individual has the right to choose their preferred treatment. The “patient rights” recommendations contained in Section 3.2 of this report “Consent to Health Care Treatment” applies equally to all forms of medical intervention in the province, including treatments for AMD.

Given the information provided by our AMD patient survey this reinforces the fact that the treatment of AMD patients should remain a priority concern given the possibility of serious harm coming to individual patients as a result of off-label treatment with Avastin.

The financial structure of BC’s wet AMD program appears to be contributing to patients being preferentially treated with off-label Avastin instead of Lucentis. The AMD Program Agreement document (obtained via a Freedom of Information request) clearly indicates that physician remuneration depends on the cost of treatment. This connection between money available for physician fees and the total program budget favours treatment with the less costly treatment option Avastin versus Lucentis.

We know that Avastin costs less than Lucentis. Therefore, if Avastin is preferentially used, it will help to ensure a robust pool of funds for physician “Administrative Fee” payments as outlined in the Program Agreement document. This works contrary to the Physicians’ Code of Ethics. The amount that is being paid to physicians as AMD treatment fees in this province deserves scrutiny.

In the past year, other provinces, notably Ontario, have reduced the procedure fees associated with intravitreal injections from $189 to $105. Between the province’s AMD program and MSP fees, British Columbia physicians net $431.85 for each AMD treatment performed. It seems excessive for physicians in this province to be paid an additional $300 administrative fee out of the AMD program budget in addition to the MSP injection fee of $131.85. According to the AMD program agreement, it appears that maximum annual Administrative Fees in the amount of $300,000 is available per physician.

Mr. Mulka, Dr. Gordon and the writer noted the financial comparison favouring Avastin over Lucentis put forth during our meeting of September 21. However, given our earlier assumptions of non-disclosure have now been confirmed as a result of our survey, we seek an answer to the following question:

  • Why are physicians in BC being remunerated significantly more than their counterparts in other Canadian provinces?

Mrs. Wallman, we appreciated the opportunity to meet with your and Dr. Lun on September 21. Your earliest possible response to the material contained herein would be appreciated.


Copies to:
Mr. John Mulka, Executive Director – CNIB BC-Yukon Division
Dr. Keith Gordon, Vice-President – Research – CNIB National